- 10 -
“5-4 Ballroom/Supper Club” in October 1991. He then attempted to
raise capital to reopen the 5-4 Ballroom by providing an
“investment opportunity” for individuals in the “5-4
Ballroom/Supper Club”. During 1992, petitioner worked with a
mortgage banking company in an effort to raise about $1.5 million
from the local Black business community. However, the effort was
unsuccessful, due to the large claim South Coast Thrift was then
asserting against petitioners and the 5401-9 S. Broadway
property.
During 1991 and 1992, petitioner also offered annual
memberships in the “5-4 Ballroom/Supper Club Inner Circle”. A
membership would entitle a person to discounts when attending
performances in the planned ballroom/supper club and also to a
birthday celebration there. Although a small amount of
membership fees was collected during 1992, no income from
membership fees was reported on petitioners’ 1992 income tax
return.5
Beginning in 1992, petitioner arranged for various
charitable events to be held on the grounds of the 5401-9 S.
Broadway property. He also arranged for an event to be held in
5Because the planned 5-4 Ballroom/Supper Club did not open,
the membership fees petitioner collected were probably refunded
or refundable, but the record does not disclose what happened to
these fees. We note, however, that respondent did not determine
that the membership fees were income to petitioners in either
1992 or 1993.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011